Robinson Cole LLP
High Contrast Mode

Raymond M. Gauvreau focuses his practice on insurance coverage advice and disputes and extra-contractual litigation. He also assists with appeals and the defense of class actions. Ray’s insurance coverage experience includes the representation of property and liability insurance carriers in connection with high-exposure litigation that often involve extra-contractual claims for damages.

Ray has assisted in the defense of Covid-19 coverage matters both at the trial and appellate level in state and federal courts and has participated in the defense of putative class action lawsuits involving commercial and homeowner’s insurance. He has experience in litigating matters across the federal and state courts of Connecticut from the pre-suit stage up to mediation or trial. Ray understands that no two cases are alike and does all he can to identify a client’s business objectives in order to secure the best possible outcome. He is a member of the firm’s Insurance + Reinsurance group.

In addition to his coverage work, Ray has experience in insurance defense, products liability, anti-SLAPP litigation, and has provided guidance on a number of education and employment law matters. Ray also has experience handling pro bono prisoners’ rights matters. Before entering private practice, he served as a legal research law clerk for the judges of the Connecticut Superior Court, where he was based in the Judicial District of Litchfield at Torrington. 

  • University of Connecticut School of Law (Juris Doctor)
    • Managing Editor of the Connecticut Journal of International Law, Volume 33
    • Hastie Moot Court Champion, Fall 2016
    • CALI Award for Excellence in Employment Law and Suing the Government
    • Connecticut Bar Association Labor and Employment Award
  • Central Connecticut State University (Bachelors, magna cum laude)
    • B.A., Political Science
    • Honors Program Graduate

  • State of Connecticut
  • U.S. District Court, District of Connecticut

Robinson+Cole Pro Bono Award, 2024

Connecticut Bar Association (2018)
Treasurer, Insurance Section (2024)

Experience


Litigation: Favorable Resolutions of Extracontractual Claims

Prepared motions to dispose of extracontractual claims from complaints in state and federal court that led to quick, favorable resolutions of said claims or the overall case either through a voluntary withdrawal or settlement.

Litigation: Special Investigative Issues

Advised insurance companies with regard to special investigative issues and how said investigations could impact coverage.

Litigation: Business Income Claim

Advised insurance company with respect to a property damage, business income, contingent business income claim stemming from significant snowstorm.



Publications


November 25, 2025

1st Circ. Offers Diversity Jurisdiction Lessons For Assignees

Law360 Expert Analysis

Practitioners know that in order to bring a diversity action in federal court, the amount in dispute must exceed the statutory minimum and there must be complete diversity of citizenship between the plaintiffs and defendants. Assignments can complicate this analysis because Title 28 of the U.S. Code, Section 1359, provides in relevant part that "[a] district court shall not have jurisdiction of a civil action in which any party, by assignment or otherwise, has been improperly or collusively made ... to invoke the jurisdiction of such court." An Oct. 16 opinion from the U.S. Court of Appeals for the First Circuit in Gore and Associates Management Co. v. SLSCO Ltd. serves as a cautionary tale about what can go wrong — dismissal after years of litigation — if an assignee invoking the jurisdiction of the federal courts has not alleged sufficient facts, or created a sufficient record, to demonstrate there is complete diversity between not only the parties to the action, but also between the putative assignors and parties on the counterparties to the assignee.[1] Background On July 6, 2019, the plaintiff Gore and Associates filed a diversity action in the U.S. District Court for the District of Puerto Rico against the defendant SLSCO and its surety, Hartford Fire Insurance Co., for alleged breach of contract, failure to pay a third-party bond claim, and a payment bond claim under the Puerto Rican Little Miller Act.[2] Specifically, Gore alleged that SLSCO failed to pay invoices submitted by Gore's nonparty subcontractors — Earthwrx LLC, Uniify of Puerto Rico LLC and Uniify Strategic Business Solutions LLC — under several federal contracts related to rebuilding projects in Puerto Rico and the U.S. Virgin Islands after 2017's Hurricane Maria. In the complaint, Gore alleged that its subcontractors assigned their respective rights under the aforementioned invoices to Gore. Preappeal Trial Court Proceedings The defendants moved to dismiss on the ground that the plaintiff's action violated a valid contractual forum selection clause, for failure to state a claim under Rule 12(b)(6) of the Federal Rules of Civil Procedure, and, in the alternative, sought a stay of any surviving claims pending completion of contractually mandated mediation proceedings, but did not challenge the court's subject matter jurisdiction pursuant to Rule 12(b)(1). The trial court dismissed without prejudice certain subcontract-related claims, but refused to dismiss claims under two specific bonds and the Little Miller Act. The district court thereafter instructed Gore to file the dismissed claims in the appropriate forums and return to this case once those claims had been disposed. The case was then stayed. Gore sought reconsideration, leave to amend their complaint and to lift the stay, but the district court denied the requested relief and an appeal followed. Diversity Issue Arises On appeal, the First Circuit sua sponte noted that the while the complaint alleged that Gore was assigned rights by Earthwrx and the Uniify entities, the record did not provide sufficient information to determine whether there was subject matter jurisdiction. As such, the First Circuit ordered the parties to provide supplemental submissions and specifically ordered Gore to provide information about the citizenship of each alleged assignor. The parties complied with the First Circuit's order to file supplemental submissions. Gore posited that the court had adequate diversity jurisdiction. In so contending, it represented that, upon information and belief, Earthwrx was wholly owned by 541 LLC, an Oregon limited liability company with a principal place of business in Oregon. Gore also represented, again upon information and belief, that Uniify of Puerto Rico, a Puerto Rican entity, was wholly owned by Uniify Strategic Business Solutions LLC, a Louisiana company. However, Gore did not submit any evidence to support its position. Unsatisfied, the First Circuit remanded the case for jurisdictional fact-finding, specifically directing the district court to determine: (1) whether each individual subcontractor was completely diverse from the defendants and, if not; (2) whether the assignments to Gore were a collusive attempt to manufacture diversity jurisdiction in violation of Section 1359. Remand Proceedings On remand, the parties agreed to exchange written discovery and reserved the right to take depositions, but no party requested an evidentiary hearing and, instead, they opted to submit simultaneous briefs with accompanying evidence on the jurisdictional issues. In support of the contention that diversity jurisdiction exists for Earthwrx, Gore submitted a certificate of formation, allowing the district court to find that Earthwrx was a Puerto Rican company and James A. Young and Bobby Owens were listed as authorized persons, administrators and members of the LLC. The court determined that none of this information was helpful in assessing whether there was complete diversity between Earthwrx and the defendants. More problematic was that this evidence contradicted Gore's prior submission to the First Circuit that suggested Earthwrx was solely owned by 541 LLC. No documentation was provided to the district court regarding 541 LLC. While Gore did submit some additional public documentation obtained regarding property purchased by Earthwrx's members, it was plainly hearsay and unauthenticated. An email chain was also submitted, but there was no context for the statements therein, even though, according to Gore, its purported purpose was to show that the assignments were to consolidate claims, avoid unnecessary litigation costs and avoid inconsistent judgments. As for the Uniify entities, the court was only able to determine that Uniify was created on Nov. 18, 2017; that Terry Bee was listed as the president, administrator and authorized person for the LLC; and that Uniify Strategic was determined to be an inactive Louisiana LLC that included Bee and Joseph P. Meyer as officers. These findings once again conflicted with Gore's prior position before the First Circuit as it had previously reported that Uniify of Puerto Rico was wholly owned by Uniify Strategic, which, according to the district court, militated against Gore's position. As it had regarding Earthwrx, Gore submitted several additional documents that also ran afoul of the Federal Rules of Evidence in that they were inadmissible hearsay, unauthenticated, unreliable, speculative, inconsistent and simply not helpful to assessing diversity as of the date the action was filed. Outcome Given the foregoing, the U.S. District Court for the District of Puerto Rico was unable to accomplish the First Circuit's remand directive and could not analyze whether there was complete diversity between any of the alleged assignors-subcontractors and defendants — much less turn to the second question of examining the motive behind a particular assignment if there was not complete diversity between any particular assignor-subcontractor and the defendants. The First Circuit held that this was fatal to Gore's suit because it bore the burden of demonstrating the validity of the assignments, as the party seeking to invoke diversity jurisdiction. While Gore sought another remand to conduct additional discovery and seek an evidentiary hearing, the First Circuit refused to do so because Gore had already been given two opportunities to provide evidence of diversity and allowed seven months for the exact purpose of conducting discovery and seeking an evidentiary hearing. The case was dismissed. Key Lessons for Assignees Seeking to Invoke Diversity Jurisdiction If an assignee plans to invoke the diversity jurisdiction of a federal court, it cannot rely solely on the diversity of the parties to the action (if first filed in state court) or eventual action. Instead, the assignee ought to conduct a rigorous investigation into the citizenship of each and every assignor whose rights the assignee is asserting prior to bringing an action. Furthermore, assuming an assignor is an LLC, it is incumbent on the assignee to investigate the citizenship of all members of such entity.[3] If the members of a particular LLC are themselves unincorporated associations, then a deeper, iterative investigation is required; the citizenship of any member must be traced through "however many layers of members or partners there may be," according to the First Circuit's 2023 decision in BRT Management LLC v. Malden Storage LLC.[4] Assuming there is complete diversity of citizenship between the assignors and defendants, the assignee can — and should — allege that to guard against a court sua sponte raising an issue with subject matter jurisdiction midsuit or, worse, after years of litigation. Better yet, an assignee ought to have evidence at its disposal to establish the citizenship of each assignor at the time the action is filed, which is the only date that matters because diversity jurisdiction is determined as of that date.[5] A subsequent change in domicile for an assignor (or any party for that matter) will not defeat existence of diversity.[6] But an assignee should not have just any evidence — it should have evidence that would be admissible under the Federal Rules of Evidence to avoid authentication, hearsay or other admissibility problems. Additionally, an assignee should be able to explain how each piece of evidence supports the diversity analysis. Failure to do so may lead to a court determining it has not been provided with sufficient evidence, which may very well be fatal if the assignee is the one attempting to invoke the diversity jurisdiction as it would bear the burden of establishing subject matter jurisdiction once raised.[7] Should an opponent of assignment raise a Section 1359 challenge to the court's diversity jurisdiction, or if the court questions its subject matter jurisdiction, and the assignee is in the awkward position of not having sufficient information or evidence to make its showing, it ought to request sufficient time to conduct a rigorous investigation into the issues such that it is not in the position of having to rely on representations made on information and belief in the first instance and then later providing contradictory information or, worse yet, evidence. Doing so will not help the assignee's credibility and could raise the specter of sanctions under Rule 11 of the Federal Rules of Civil Procedure. Key Lessons for Nonassignee Opponents Conversely, a nonassignee should investigate any assignment-related allegations or disclosures thoroughly. If the non-assignee has a good faith basis to suspect that diversity jurisdiction exists only as the result of an assignment, then it should alert the federal court to the potential jurisdictional defect. This will force the assignee to provide the court with sufficient, admissible evidence that there was complete diversity at the commencement of the action and avoid an issue raised years later on appeal. If the assignee fails to do so, then the nonassignee ought to detail the deficiencies in the assignee's evidence and explain to the court how the assignee's burden has not been met. A Note on the Presumption of an Invalid Assignment If the district court on remand was unable to analyze whether there was complete diversity between any of Gore's assignor-subcontractors and the defendant (SLSCO) and its surety (Hartford Fire Insurance), that would have been the end of the analysis. However, if the district court determined that there was incomplete diversity between defendants and a particular assignor-subcontractor, then that assignment would have been presumptively ineffective for purposes of Section 1359.[8] While rebutting this presumption is "likely to be difficult," it is incumbent on the assignee-party to prove that it was not made collusively by way of a "credible showing of a legitimate reason for the transfer" that was "unrelated to the fabrication of federal court jurisdiction," according to the U.S. Court of Appeals for the Eighth Circuit's 2004 opinion in McCulloch v. Velez.[9] Given that credibility is in play to rebut this collusion presumption, live testimony likely will be advisable, if not absolutely necessary. Indeed, had the district court turned to the second question on remand, it telegraphed its displeasure with the documentary submission of an email that provided no context for the statements therein despite said email purporting to be evidence of a valid purpose for the assignments. Gore and Assocs. Mgmt. Co. v. SLSCO Ltd., --- F.4th ---, 2025 WL 2938795 (1st Cir. 2025). P.R. Laws Ann. Tit. 22, § 51. BRT Mgmt. LLC v. Malden Storage LLC, 68 F.4th 691, 696 (1st Cir. 2023) (internal quotation marks omitted). Id. Bank One, Texas, N.A. v. Montle, 964 F.2d 48, 49 (1st Cir. 1992). Id. E.g., Woo v. Spackman, 988 F.3d 47, 53 (1st Cir. 2021) (party who asserts jurisdiction bears burden of establishing that it exists by a preponderance of the evidence). McCulloch v. Velez, 364 F.3d 1, 6 (8th Cir. 2004). Id.

November 25, 2025

1st Circ. Offers Diversity Jurisdiction Lessons For Assignees

Law360 Expert Analysis

Practitioners know that in order to bring a diversity action in federal court, the amount in dispute must exceed the statutory minimum and there must be complete diversity of citizenship between the plaintiffs and defendants. Assignments can complicate this analysis because Title 28 of the U.S. Code, Section 1359, provides in relevant part that "[a] district court shall not have jurisdiction of a civil action in which any party, by assignment or otherwise, has been improperly or collusively made ... to invoke the jurisdiction of such court." An Oct. 16 opinion from the U.S. Court of Appeals for the First Circuit in Gore and Associates Management Co. v. SLSCO Ltd. serves as a cautionary tale about what can go wrong — dismissal after years of litigation — if an assignee invoking the jurisdiction of the federal courts has not alleged sufficient facts, or created a sufficient record, to demonstrate there is complete diversity between not only the parties to the action, but also between the putative assignors and parties on the counterparties to the assignee.[1] Background On July 6, 2019, the plaintiff Gore and Associates filed a diversity action in the U.S. District Court for the District of Puerto Rico against the defendant SLSCO and its surety, Hartford Fire Insurance Co., for alleged breach of contract, failure to pay a third-party bond claim, and a payment bond claim under the Puerto Rican Little Miller Act.[2] Specifically, Gore alleged that SLSCO failed to pay invoices submitted by Gore's nonparty subcontractors — Earthwrx LLC, Uniify of Puerto Rico LLC and Uniify Strategic Business Solutions LLC — under several federal contracts related to rebuilding projects in Puerto Rico and the U.S. Virgin Islands after 2017's Hurricane Maria. In the complaint, Gore alleged that its subcontractors assigned their respective rights under the aforementioned invoices to Gore. Preappeal Trial Court Proceedings The defendants moved to dismiss on the ground that the plaintiff's action violated a valid contractual forum selection clause, for failure to state a claim under Rule 12(b)(6) of the Federal Rules of Civil Procedure, and, in the alternative, sought a stay of any surviving claims pending completion of contractually mandated mediation proceedings, but did not challenge the court's subject matter jurisdiction pursuant to Rule 12(b)(1). The trial court dismissed without prejudice certain subcontract-related claims, but refused to dismiss claims under two specific bonds and the Little Miller Act. The district court thereafter instructed Gore to file the dismissed claims in the appropriate forums and return to this case once those claims had been disposed. The case was then stayed. Gore sought reconsideration, leave to amend their complaint and to lift the stay, but the district court denied the requested relief and an appeal followed. Diversity Issue Arises On appeal, the First Circuit sua sponte noted that the while the complaint alleged that Gore was assigned rights by Earthwrx and the Uniify entities, the record did not provide sufficient information to determine whether there was subject matter jurisdiction. As such, the First Circuit ordered the parties to provide supplemental submissions and specifically ordered Gore to provide information about the citizenship of each alleged assignor. The parties complied with the First Circuit's order to file supplemental submissions. Gore posited that the court had adequate diversity jurisdiction. In so contending, it represented that, upon information and belief, Earthwrx was wholly owned by 541 LLC, an Oregon limited liability company with a principal place of business in Oregon. Gore also represented, again upon information and belief, that Uniify of Puerto Rico, a Puerto Rican entity, was wholly owned by Uniify Strategic Business Solutions LLC, a Louisiana company. However, Gore did not submit any evidence to support its position. Unsatisfied, the First Circuit remanded the case for jurisdictional fact-finding, specifically directing the district court to determine: (1) whether each individual subcontractor was completely diverse from the defendants and, if not; (2) whether the assignments to Gore were a collusive attempt to manufacture diversity jurisdiction in violation of Section 1359. Remand Proceedings On remand, the parties agreed to exchange written discovery and reserved the right to take depositions, but no party requested an evidentiary hearing and, instead, they opted to submit simultaneous briefs with accompanying evidence on the jurisdictional issues. In support of the contention that diversity jurisdiction exists for Earthwrx, Gore submitted a certificate of formation, allowing the district court to find that Earthwrx was a Puerto Rican company and James A. Young and Bobby Owens were listed as authorized persons, administrators and members of the LLC. The court determined that none of this information was helpful in assessing whether there was complete diversity between Earthwrx and the defendants. More problematic was that this evidence contradicted Gore's prior submission to the First Circuit that suggested Earthwrx was solely owned by 541 LLC. No documentation was provided to the district court regarding 541 LLC. While Gore did submit some additional public documentation obtained regarding property purchased by Earthwrx's members, it was plainly hearsay and unauthenticated. An email chain was also submitted, but there was no context for the statements therein, even though, according to Gore, its purported purpose was to show that the assignments were to consolidate claims, avoid unnecessary litigation costs and avoid inconsistent judgments. As for the Uniify entities, the court was only able to determine that Uniify was created on Nov. 18, 2017; that Terry Bee was listed as the president, administrator and authorized person for the LLC; and that Uniify Strategic was determined to be an inactive Louisiana LLC that included Bee and Joseph P. Meyer as officers. These findings once again conflicted with Gore's prior position before the First Circuit as it had previously reported that Uniify of Puerto Rico was wholly owned by Uniify Strategic, which, according to the district court, militated against Gore's position. As it had regarding Earthwrx, Gore submitted several additional documents that also ran afoul of the Federal Rules of Evidence in that they were inadmissible hearsay, unauthenticated, unreliable, speculative, inconsistent and simply not helpful to assessing diversity as of the date the action was filed. Outcome Given the foregoing, the U.S. District Court for the District of Puerto Rico was unable to accomplish the First Circuit's remand directive and could not analyze whether there was complete diversity between any of the alleged assignors-subcontractors and defendants — much less turn to the second question of examining the motive behind a particular assignment if there was not complete diversity between any particular assignor-subcontractor and the defendants. The First Circuit held that this was fatal to Gore's suit because it bore the burden of demonstrating the validity of the assignments, as the party seeking to invoke diversity jurisdiction. While Gore sought another remand to conduct additional discovery and seek an evidentiary hearing, the First Circuit refused to do so because Gore had already been given two opportunities to provide evidence of diversity and allowed seven months for the exact purpose of conducting discovery and seeking an evidentiary hearing. The case was dismissed. Key Lessons for Assignees Seeking to Invoke Diversity Jurisdiction If an assignee plans to invoke the diversity jurisdiction of a federal court, it cannot rely solely on the diversity of the parties to the action (if first filed in state court) or eventual action. Instead, the assignee ought to conduct a rigorous investigation into the citizenship of each and every assignor whose rights the assignee is asserting prior to bringing an action. Furthermore, assuming an assignor is an LLC, it is incumbent on the assignee to investigate the citizenship of all members of such entity.[3] If the members of a particular LLC are themselves unincorporated associations, then a deeper, iterative investigation is required; the citizenship of any member must be traced through "however many layers of members or partners there may be," according to the First Circuit's 2023 decision in BRT Management LLC v. Malden Storage LLC.[4] Assuming there is complete diversity of citizenship between the assignors and defendants, the assignee can — and should — allege that to guard against a court sua sponte raising an issue with subject matter jurisdiction midsuit or, worse, after years of litigation. Better yet, an assignee ought to have evidence at its disposal to establish the citizenship of each assignor at the time the action is filed, which is the only date that matters because diversity jurisdiction is determined as of that date.[5] A subsequent change in domicile for an assignor (or any party for that matter) will not defeat existence of diversity.[6] But an assignee should not have just any evidence — it should have evidence that would be admissible under the Federal Rules of Evidence to avoid authentication, hearsay or other admissibility problems. Additionally, an assignee should be able to explain how each piece of evidence supports the diversity analysis. Failure to do so may lead to a court determining it has not been provided with sufficient evidence, which may very well be fatal if the assignee is the one attempting to invoke the diversity jurisdiction as it would bear the burden of establishing subject matter jurisdiction once raised.[7] Should an opponent of assignment raise a Section 1359 challenge to the court's diversity jurisdiction, or if the court questions its subject matter jurisdiction, and the assignee is in the awkward position of not having sufficient information or evidence to make its showing, it ought to request sufficient time to conduct a rigorous investigation into the issues such that it is not in the position of having to rely on representations made on information and belief in the first instance and then later providing contradictory information or, worse yet, evidence. Doing so will not help the assignee's credibility and could raise the specter of sanctions under Rule 11 of the Federal Rules of Civil Procedure. Key Lessons for Nonassignee Opponents Conversely, a nonassignee should investigate any assignment-related allegations or disclosures thoroughly. If the non-assignee has a good faith basis to suspect that diversity jurisdiction exists only as the result of an assignment, then it should alert the federal court to the potential jurisdictional defect. This will force the assignee to provide the court with sufficient, admissible evidence that there was complete diversity at the commencement of the action and avoid an issue raised years later on appeal. If the assignee fails to do so, then the nonassignee ought to detail the deficiencies in the assignee's evidence and explain to the court how the assignee's burden has not been met. A Note on the Presumption of an Invalid Assignment If the district court on remand was unable to analyze whether there was complete diversity between any of Gore's assignor-subcontractors and the defendant (SLSCO) and its surety (Hartford Fire Insurance), that would have been the end of the analysis. However, if the district court determined that there was incomplete diversity between defendants and a particular assignor-subcontractor, then that assignment would have been presumptively ineffective for purposes of Section 1359.[8] While rebutting this presumption is "likely to be difficult," it is incumbent on the assignee-party to prove that it was not made collusively by way of a "credible showing of a legitimate reason for the transfer" that was "unrelated to the fabrication of federal court jurisdiction," according to the U.S. Court of Appeals for the Eighth Circuit's 2004 opinion in McCulloch v. Velez.[9] Given that credibility is in play to rebut this collusion presumption, live testimony likely will be advisable, if not absolutely necessary. Indeed, had the district court turned to the second question on remand, it telegraphed its displeasure with the documentary submission of an email that provided no context for the statements therein despite said email purporting to be evidence of a valid purpose for the assignments. Gore and Assocs. Mgmt. Co. v. SLSCO Ltd., --- F.4th ---, 2025 WL 2938795 (1st Cir. 2025). P.R. Laws Ann. Tit. 22, § 51. BRT Mgmt. LLC v. Malden Storage LLC, 68 F.4th 691, 696 (1st Cir. 2023) (internal quotation marks omitted). Id. Bank One, Texas, N.A. v. Montle, 964 F.2d 48, 49 (1st Cir. 1992). Id. E.g., Woo v. Spackman, 988 F.3d 47, 53 (1st Cir. 2021) (party who asserts jurisdiction bears burden of establishing that it exists by a preponderance of the evidence). McCulloch v. Velez, 364 F.3d 1, 6 (8th Cir. 2004). Id.


News


December 3, 2025

Ray Gauvreau Authors Article on Diversity Jurisdiction

Insurance + Reinsurance group lawyer Ray Gauvreau recently authored an article titled “1st Circ. Offers Diversity Jurisdiction Lessons For Assignees” published in Law360 Expert Analysis on November 25, 2025. In an expansion of his post for the firm’s Covering Appeals blog, Ray discusses an October 16, 2025, opinion from the U.S. Court of Appeals for the First Circuit reminding practitioners that when federal diversity jurisdiction is asserted and a claim has been assigned, an assignee must prove the citizenship of not just itself, but also of every assignor. Failure to do so can be fatal. “If an assignee plans to invoke the diversity jurisdiction of a federal court, it cannot rely solely on the diversity of the parties to the action, or eventual action,” writes Ray. “Instead, the assignee ought to conduct a rigorous investigation into the citizenship of each and every assignor whose rights the assignee is asserting prior to bringing the action.” To read the article, click here.

Law360 Expert Analysis
September 3, 2025

Robinson+Cole Insurance Practice Launches Latest Blog, Covering Appeals

New resource expands firm’s industry insights, unpacking the latest, high-impact insurance coverage appellate cases and trends
Robinson+Cole Insurance Practice Launches Latest Blog, <i>Covering Appeals</i> teaser
August 1, 2024

Robinson+Cole Presents 2024 Awards

December 3, 2025

Ray Gauvreau Authors Article on Diversity Jurisdiction

Insurance + Reinsurance group lawyer Ray Gauvreau recently authored an article titled “1st Circ. Offers Diversity Jurisdiction Lessons For Assignees” published in Law360 Expert Analysis on November 25, 2025. In an expansion of his post for the firm’s Covering Appeals blog, Ray discusses an October 16, 2025, opinion from the U.S. Court of Appeals for the First Circuit reminding practitioners that when federal diversity jurisdiction is asserted and a claim has been assigned, an assignee must prove the citizenship of not just itself, but also of every assignor. Failure to do so can be fatal. “If an assignee plans to invoke the diversity jurisdiction of a federal court, it cannot rely solely on the diversity of the parties to the action, or eventual action,” writes Ray. “Instead, the assignee ought to conduct a rigorous investigation into the citizenship of each and every assignor whose rights the assignee is asserting prior to bringing the action.” To read the article, click here.

Law360 Expert Analysis
September 3, 2025

Robinson+Cole Insurance Practice Launches Latest Blog, Covering Appeals

New resource expands firm’s industry insights, unpacking the latest, high-impact insurance coverage appellate cases and trends
Robinson+Cole Insurance Practice Launches Latest Blog, <i>Covering Appeals</i> teaser
August 1, 2024

Robinson+Cole Presents 2024 Awards

Events


Past

Assignment of Benefits: A Fraudster’s Playground

Mar 23 2026
PLRB 2026 Claims Conference
Past

Stacking Coverage Under UM and UIM Policies: Identifying All Coverages, Preventing Misapplication of Stacking Rules

Sep 6 2022
Strafford webinar
Past

Assignment of Benefits: A Fraudster’s Playground

Mar 23 2026
PLRB 2026 Claims Conference
Past

Stacking Coverage Under UM and UIM Policies: Identifying All Coverages, Preventing Misapplication of Stacking Rules

Sep 6 2022
Strafford webinar

Covering Appeals


Below is an excerpt of the Covering Appeals posts authored by Ray.

A Tale of Two Timelines – Eleventh Circuit Rejects Claimant’s Attempt to Rewrite Occurrence Notice Condition

Occurrence-based liability policies often include a condition that requires the insured, or someone on their behalf, to provide a carrier prompt notice of the occurrence. Delays in reporting a claim can potentially provide a carrier with a late notice defense. The viability of this defense can turn on whether timeliness is evaluated from the perspective... Continue Reading

Visit Blog

Assignees Can’t Collude Their Way Into Federal Court

In Gore and Associates Management Company, Inc. v. SLSCO Ltd., — F.4th —, 2025 WL 2938795 (2025), Plaintiff Gore and Associates Management Company sued Defendant SLSCO Ltd. and its surety, Hartford Fire Insurance Company, as an assignee, for alleged financial losses Gore’s subcontractors (all LLCs) sustained after SLSCO and Hartford Fire allegedly failed to pay... Continue Reading

Visit Blog

Welcome to Robinson+Cole’s “Covering Appeals” Blog

Welcome to Robinson+Cole’s Covering Appeals blog, a new resource that analyzes the latest developments in insurance coverage appeals and provides an in-depth analysis of industry trends. Our Insurance Appeals team is known for handling cutting-edge and precedent-setting insurance appeals nationwide, having been involved in key cases arising from the COVID-19 business interruption insurance litigation, Chinese-manufactured... Continue Reading

Visit Blog